Mark, when I read this I was a bit surprised – I got the 15 million number directly from the Director of Collections, Paul Mamo, in January. So I went and looked and confirmed what you found, and then I spoke with Paul yesterday and asked him about this. What he explained is that the data book number does not include the several million accounts transferred to the private debt collectors. He held firm with the 15 million number.
What he also told me is that he does expect the number for 2020 to fall before it surges in 2021, and that is because given that moratorium on enforcement, returns filed this year after March 15th with balances due are not being moved into the collection area, which would trigger the 500 series letters (CP 504, etc). Hence we will probably see a drop for 2020, which is really a timing issue. he has assured me that, based upon what he is seeing from his office the number is going to climb significantly in 2021.
Great catch, by the way! I am going to put this in an email out to the members.